# Bluespruce

> Bluespruce is an SEC-registered investment advisory firm in Chicago, IL, registered since 2013, reporting $1 billion to $5 billion in regulatory assets under management in its Form ADV filing dated July 29, 2026.

- CRD: 167311
- Filed as: BLUESPRUCE
- Legal name: Bluespruce Investments, LP
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Chicago, IL
- Filing period: October 2026
- Form ADV filing dated: July 29, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/167311
- AdvisorCensus page: https://advisorcensus.com/firm/bluespruce-chicago-il-167311

## Quick answers

**How is Bluespruce compensated?**
On its Form ADV (Item 5.E, October 2026), Bluespruce reports these compensation arrangements: a percentage of assets under its management; performance-based fees.

**Where is Bluespruce located?**
Bluespruce's principal office is in Chicago, IL, according to its Form ADV.

**Is Bluespruce registered with the SEC or a state?**
Bluespruce is an SEC-registered investment advisory firm, registered since 2013. Status as filed: Approved. CRD 167311.

**How much does Bluespruce manage?**
Bluespruce reports $4,454,268,000 in regulatory assets under management in its Form ADV filing dated July 29, 2026 (100% discretionary).

**How have Bluespruce's assets and staff changed since 2021?**
In the Form ADV data for Bluespruce: Regulatory assets under management: $5,344,651,000 in the October 2021 data and $4,454,268,000 in the October 2026 data, down 17%. Total employees: 9 in October 2021 and 10 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Bluespruce serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (2).

**Does Bluespruce report any disciplinary disclosures?**
Reports no disclosure items on Form ADV Item 11. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/167311

**Does Bluespruce state an account minimum?**
Its Form ADV Part 2A brochure dated March 30, 2026 says: "Minimum initial contributions for investment in each Fund are $5 million but contributions of less than such amount are accepted at the sole discretion of the respective Fund’s General Partner."

**What changed in Bluespruce's recent Form ADV filings?**
In the April 2026 filing data: Employees performing advisory functions went from 13 to 10. Regulatory assets under management went from $5,737,136,000 to $4,454,268,000 (-22%). Updated its list of owners and control persons (Schedule A).

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management
- Performance-based fees

### Fees and minimums (Form ADV Part 2A brochure dated March 30, 2026)

- Account minimum: $5,000,000 (the brochure says it may be waived or negotiated)

> Minimum initial contributions for investment in each Fund are $5 million but contributions of less than such amount are accepted at the sole discretion of the respective Fund’s General Partner.

As stated in the firm's brochure. Fees can differ by service and may be negotiable.

### Regulatory assets under management (Item 5.F)
- Total: $4,454,268,000
- Discretionary: $4,454,268,000
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 0 | Not reported |
| High net worth individuals | 0 | Not reported |
| Banking or thrift institutions | 0 | Not reported |
| Investment companies | 0 | Not reported |
| Business development companies | 0 | Not reported |
| Pooled investment vehicles (other than investment companies and business development companies) | 2 | $4,454,268,000 |
| Pension and profit sharing plans (but not the plan participants or government pension plans) | 0 | Not reported |
| Charitable organizations | 0 | Not reported |
| State or municipal government entities (including government pension plans) | 0 | Not reported |
| Other investment advisers | 0 | Not reported |
| Insurance companies | 0 | Not reported |
| Sovereign wealth funds and foreign official institutions | 0 | Not reported |
| Corporations or other businesses not listed above | 0 | Not reported |
| Other | 0 | Not reported |

### Advisory services (Item 5.G)
- Portfolio management for pooled investment vehicles (other than investment companies)

### Firm details
- Registered since: 2013 (13 years)
- Employees: 10 total, 10 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: IL
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- bluesprucelp.com
- LinkedIn @bluespruce-investments

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $5,344,651,000 | 9 | August 3, 2021 |
| October 2022 | $6,733,848,000 | 10 | March 8, 2022 |
| October 2023 | $5,367,919,000 | 11 | February 27, 2023 |
| October 2024 | $5,928,256,000 | 13 | August 15, 2024 |
| October 2025 | $5,737,136,000 | 13 | March 11, 2025 |
| October 2026 | $4,454,268,000 | 10 | July 29, 2026 |

Regulatory assets under management: $5,344,651,000 in the October 2021 data and $4,454,268,000 in the October 2026 data, down 17%.
Total employees: 9 in October 2021 and 10 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Employees performing advisory functions went from 13 to 10.
- Regulatory assets under management went from $5,737,136,000 to $4,454,268,000 (-22%).
- Updated its list of owners and control persons (Schedule A).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Bluespruce (CRD 167311): Form ADV filing data as of October 2026.